Code of Conduct

The Code of Conduct (CoC) defines the fundamental values of our bank, and it serves as the foundation for our ethically responsible corporate culture in conformance with statutory regulations. The Code of Conduct is binding for all employees, and it ensures that the highest standards are observed in our business and ethical behaviour.

If you have any question regarding the list of authorized signatures or how to get a password, please contact:

Virtual Currencies

Background

The virtual currency is a form of unregulated, digital currency that is created and usually controlled by its developers and used among members of a particular virtual community. The rapid development of the digital market has led to the emergence of different types of virtual currencies.

Virtual currencies can be purchased through online trading platforms (virtual money exchange houses – well known trading platforms are Kraken, Coinbase and Bitstamp). with conventional currencies. They are then transferred to a personal account, the digital "wallet". Through this wallet consumers are able to either transfer Bitcoins online to recipients who then accept the currency, or exchange Bitcoins back to conventional money (e.g. Euro, Pounds or Dollars).

Regulatory measures

In its opinion on cryptocurrency or virtual currencies, the European Banking Authority identifies about 70 potential risks that may arise from the use of a virtual currency. In this regard, the FATF and EBA expect from credit and financial institutions to apply appropriate risk-based measures in relation to transactions involving virtual currencies. Both the FATF and EBA associate payments in connection with virtual currencies with a high degree of risk with regard to money laundering,terrorism financing and avoidance of sanctions. Therefore, the application of enhanced due diligence measures is required toward such payments which are for the amount of 1000 euro or their equivalence in other currency, incl. the demand of additional documents– the minimum documentation requirement is a filled declaration for source of funds for each incoming/outgoint transaction.

RBI Group approach

In order to protect the interests of its clients and due to the lack of legal regulation at European and national level for this type of currency the RBI Group and respectively Raiffeisenbank (Bulgaria) EAD is not allowed execute payments related to virtual currencies, due to the following reasons:

Part of the correspondent banks with which Raiffeisenbank (Bulgaria) EAD operates refuse to accept transfers for the purchase and sale of virtual currency.

The virtual currencies are not recognized as a legal payment instrument up to now.

There is no legal framework created in order to regulate the trading of virtual currencies and its participants, respectively there are no regulatory rules for protection of users of such services.

The platforms, providing opportunities for trading/payments with virtual currencies, are not regulated both on a local and European level.

High level of anonymity of the owners and beneficiaries of these transactions.

Payments in connection to virtual currencies are considered to be of a higher risk for transactions that could serve crimes such as money laundering and financing terorism.

There is no method or authority to provide compensation to the consumer in cases of unauthorized or erroneous transactions related to virtual currencies.

The risk and the responsibility arising from acquisition and transaction of virtual currencies falls on the individuals executing the operation.

Information on Fraudulent Scheme

LEI

LEI (Legal Entity Identifier) is an international identifier for legal entities. This identifier allows the registered entities to identify themselves in a unified way when entering into transactions with financial instruments.

The LEI number of Raiffeisenbank (Bulgaria) EAD is 5299009KAL4KO7584196.

FATCA

FATCA at Raiffeisen Bank

The Foreign Account Tax Compliance Act (FATCA) is a US legislation that was enacted in March 18, 2010 and that will enter into force on July 1, 2014. FATCA is essentially a regulatory reporting requirement for foreign financial institutions on their US account holder base. All units of Raiffeisen Bank International and RZB Group have recognized the importance of FATCA and comply with the FATCA requirements.

Raiffeisen Bank Bulgaria EAD has already registered itself on the U.S. IRS website with the FATCA Status Registered Deemed-Compliant Financial Institution covered by a Model 1 IGA and has received 28CWN4.00014.ME.100 as Global Intermediary Identification Number (GIIN).

In addition Bulgaria is one of the jurisdictions that are treated by U.S. as having an intergovernmental agreement in effect. Bulgaria has reached an agreement in substance and has consented to being included on the list of countries published by the U.S. IRS on their website.

CRS

What is the Common Reporting Standard (CRS)?

In 2014 the Organisation for Economic Cooperation and Development (OECD) has published a global Standard for the Automatic Exchange of Financial Account Information. The so called Common Reporting Standard (CRS) essentially constitutes a regulatory reporting requirement for Financial Institutions seated in participating jurisdictions (currently more than 100 jurisdictions) and pursues the aim to avoid tax evasion.

In December 2014 the CRS was implemented in the EU-Directive on Administrative Assistance in Tax Matters. Due to that European Member States were obligated to implement the provisions into national law. In Bulgaria this Standard was implemented into national law / Tax and Social Security Procedure Code / in August 2015.

Customer Identification, Documentation and Reporting

According to the provisions set forth in the Tax and Social Security Procedure Code/TSSPC/ in Bulgaria the banks are obligated to implement appropriate measures to identify their customer’s tax residence (relevant customers are private individuals, entities and under certain circumstances controlling persons) and the Tax Identification Number of the respective jurisdiction of tax residence. Financial Institutions are further required to report financial accounts maintained by customers who are resident for tax purposes in a participating jurisdiction to the national tax authority /National revenue agency or NRA/ which again may exchange the information with the tax authorities of another country or countries in which the customer (or in certain cases the controlling persons) may be tax resident.

Bulgaria committed to participate in the OECD Automated Exchange Of Information (AEOI) and to implemented CRS in local jurisdiction

Starting on 1 January 2016 Financial Institutions seated in Bulgaria are obligated to implement procedures and measures in order to meet the due diligence obligations according to TSSPC. Hence all customers who want to open a new account are required to provide a reasonable Self-Certification to determine their tax residence(s) and their respective Tax Identification Number(s)

Under certain circumstances also for Pre-existing Accounts/Pre-existing Customers that do not open a new account are also required to provide a reasonable Self-Certification in order to clearly determine their tax residence(s) and their Tax Identification Number(s). In general the necessary TIN information to be provided by the customer correlates with the unlimited income tax liability of the tax resident in the country of tax residence.

Mandatory Self-Certifications for all (new) Accounts/Customers

It should be pointed out that the obligation to provide a reasonable Self-Certification applies for all customers, irrespective of their tax residence, thus, also for customers who are exclusively tax resident in Bulgaria.

If customers are unsure about their tax residence(s), they should consult their tax adviser in order to clarify their residence(s) for tax purposes. Moreover, customers may also consult certain information centers of the Bulgarian tax authority. It is important to emphasize that Financial Institutions are prohibited from providing any tax or legal advice.

Reportable Data according to CRS/ TSSPC

The report of financial accounts includes certain data about the account holder (in certain cases also about the controlling person) as well as data about the account.

According to the provisions of the TSSPC the following information has to be reported to the tax authority:

account balances or values as of the end of the calendar year or the closure of the account

the total gross amount of income, dividends or other income generated with respect to the assets held in the account, as well as total gross proceeds from the sale or redemption of financial assets, in each case paid or credited to the account during the calendar year or other reporting period

In the case of entities additionally the controlling person(s) of the entity, identified in accordance with the provisions of the TSSPC:

Name

Address

Jurisdiction(s) of Residence

Tax Identification Number(s)

Date and place of birth

Non reportable "excluded" accounts

In this regard the legislator has also defined list of excluded accounts within the meaning of § 1a item 39 letter "g" from the additional provisions of TSSPC for accounts which are not reportable financial accounts.

Non reportable persons

Furthermore an exemption exists for specific customers who are not defined as "reportable persons" according to 1a item 12 from the additional provisions of TSSPC. These are Financial Institutions, Governmental Entity, International Organizations, Central Banks, Corporations the stock of which is regularly traded on one or more established securities markets (or a related entity thereof).

Further information about the OECD Common Reporting Standard can be found: